Taxation

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Journals/Magazines

A Better Way to Tax U.S. Businesses.
The U.S. corporate tax code is broken. High rates and perverse incentives drive capital away from the corporate sector and toward other uses and countries. This is bad news for U.S. workers, because corporations aren’t making investments that would increase productivity and real wages. And while one might think higher rates lead to higher revenues, the U.S. actually collects less in taxes (as a percentage of GDP) than most other developed nations. Desai, a professor at Harvard Business School and Harvard Law, believes a handful of changes could fix all that. A significant rate reduction and an end to foreign income tax would encourage U.S. multinationals to keep more money at home. Any revenue lost could be offset by a small tax on noncorporate business income, which is now exempted. Closing the chasm between how income is reported on taxes and earnings are reported to investors would also raise revenue—and end public perceptions of unfairness. These reforms could actually turn the U.S. tax system into an asset. But they won’t be effective if managers don’t change their mind-set. Rather than shirking their tax obligations, they need to start viewing them as an important social responsibility.
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A Do-lt-Yourself Tax Cut.
The article offers personal finance information related to taxes in the U.S., as of December 2013. It notes tax changes affecting high-income households, including changes related to itemized deductions, income tax rates, and dividend and long-term capital gains tax rates. Tax-lowering strategies related to investments are presented.
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Brazil: Important changes to Brazilian CFC legislation. Some full text available
The article reports that the Brazilian government published on November 12, 2013 Provisional Measure (MP) Number 627 which changes many aspects of the Brazilian tax system. It indicates that among the changes is the taxation of profits by controlled foreign corporations (CFC). It informs that taxpayers will be allowed to consolidate positive and negative adjustments until 2017 under specific conditions.
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For Better or for Worse: Will the Repeal of the Defense of Marriage Act Bring Couples Happiness? Some full text available
There are numerous tax planning issues that now need to be addressed for same-sex married couples. While some will enjoy tax benefits from their new status, others will suffer tax consequences.
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Gender, poverty and taxation: An overview of a multi-country study of gender and taxation Some full text available
While gender-budgeting has grown in prominence gender activists and policymakers have paid insufficient attention to the taxation side of public finance. Drawing on a three-year eight-country study this Profile outlines why gender activists should be concerned about the revenue side of the budget, shares the conceptual approach, methodology and some of the research findings of the study, and highlights key policy issues flowing from the research. The project found that income taxes continued to be biased against women. Somewhat against expectations, because these were carefully designed, value-added taxes in all of the countries studied did not appear to place an undue burden on poor women.
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India: Ruling on eligibility of fiscally transparent entity for tax treaty benefits. Some full text available
The article discusses the ruling on the case of taxpayer M/s A.P. Moller regarding the eligibility of a fiscally transparent entity for availing benefits of the India-Denmark double taxation avoidance agreement (DTAA). The taxpayer is a partnership firm established in Denmark and is engaged in the management of shipping operations at global level, including India. The Indian Tax Authority claims that management fees earned by the taxpayer are taxable in India.
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International Taxation and the Direction and Volume of Cross-Border M&As. Some full text available
We show that the parent-subsidiary structure of multinational firms created by cross-border mergers and acquisitions is affected by the prospect of international double taxation. Specifically, the likelihood of parent firm location in a country following a cross-border takeover is reduced by high international double taxation of foreign-source income. At the same time, countries with high international double taxation attract smaller numbers of parent firms. A unilateral elimination of worldwide taxation by the United States is simulated to increase the proportion of parent firms locating in the United States following cross-border mergers and acquisitions from 53% to 58%. [ABSTRACT FROM AUTHOR]
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Losses and Expenses in the European Union. Some full text available
The article discusses the author's views on the territorial revenues and expenses related to taxation of foreign investments in the European Union (EU). He explores the cross-border situations in the context of the double tax treaties in the different states under the EU. The author believes that the territoriality principle justifies the unequal treatment of cross-border situations on double taxation which presses the need for a balanced allocation of taxation rights among the EU states.
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Multinational Taxation and R&D Investments. Some full text available
This study examines the effects of taxation on the incentives of multinational firms to develop and use intellectual property. We model optimal investment and production decisions by firms that engage in a patent race by making R&D investments. We investigate how taxes affect the level and efficiency of R&D investments, and how these effects depend on whether the winner of the patent race uses it by either producing in the country in which the patent was developed (the domestic country) or in a foreign country. A higher domestic tax rate decreases investment in R&D if production occurs in the domestic country, but increases investment in R&D if production occurs in the foreign country. The present value of domestic tax revenues is strictly positive if production occurs in the domestic country, but is weakly negative if production occurs in the foreign country.
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No taxation, no democracy? Taxation, income inequality, and democracy Some full text available
Does taxation promote democracy? Revisiting this question, I hypothesize that the effects of taxation on democracy tend to be relatively stronger in unequal societies because higher income inequality can amplify the extent to which citizens dissatisfied with higher levels of taxation want to soak elites. Using event history models to analyze a pooled time-series dataset of regime transitions that cover all countries from 1970 to 2000 if data are applicable, I find empirical evidence that taxation has a conditional impact on democratization, but not on democratic breakdown. According to the theory, higher taxation levels and greater income inequality should tend to promote democracy.
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Polish proposals prompt double taxation concerns. Some full text available
The article highlights that Poland's proposed changes to its controlled foreign corporation (CFC) rules and thin capitalisation regime could increase the risk of double taxation. It is said that the CFC rules will be applicable to foreign branch income, even if a treaty provides exemption for foreign permanent establishment income. Lukasz Kupryjanczyk, manager in the tax advisory department of financial services firm EY Poland, says the rules will subject taxpayers to 19% tax.
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Poverty, taxation and governance Some full text available
In a simple model based on political support approach, we show that poor and less egalitarian societies may impose a lower tax rate contrary to the prediction of the median voter approach. This is consistent with the available empirical findings. In the framework developed in this paper, the government can strategically design a weak governance system to promote informal activities for the poor. This constitutes an alternative redistributive strategy other than the standard tax-transfer policy. The government chooses the tax rate and the degree of governance simultaneously to maximize the average income of the poor in the informal sector of the economy, i.e. those who constitute the majority and help in winning the election.
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Tax Revenue Manipulation by Local Taxation Administrations in China Some full text available
This paper investigates the tax revenue manipulation in China by local taxation administrations to achieve a sustainable performance. We document a higher volatility in the effective corporate income tax rates for those companies registering in provinces with more tax sources caused by the manipulation. We also find that companies' ability to pay tax is negatively correlated with the probability of being selected by local taxation administrations for the purpose of tax revenue manipulation. Second, local taxation administrations' relationships with companies and the subsidy allocated to companies have no significant effect on this selection.
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The Effect of Political Sensitivity and Bargaining Power on Taxes: Evidence from Federal Contractors. Some full text available
We investigate whether politically sensitive contractors pay higher taxes and whether their bargaining power reduces these tax costs. Using federal contractor data, we develop a new composite measure of political sensitivity that captures both the political visibility arising from federal contracts and the importance of federal contracts to the firm. We proxy for bargaining power using the firm-level proportion of contract revenues not subject to competition, the firm-level proportion of contract revenues arising from defense contracts, and industry-level concentration ratios. We find that politically sensitive firms pay higher federal taxes, all else equal. However, firms with greater bargaining power incur fewer tax-related political costs. Our study provides new evidence on the political cost hypothesis in a tax setting and the first evidence of the interactive effects of a firm's political sensitivity and bargaining power on tax-related political costs.
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Why government should not collect taxes’: grand corruption in government and citizens' views on taxation in Cameroon Some full text available

This paper explores how Cameroonians view the payment of taxes to the Cameroonian state in the backdrop of the pervasive corruption and the dismal levels of social service provision characterising public governance in the country since the early 1990s. It does so by combining a review of secondary literature about the nature of state–society relations in Cameroon and public opinion surveys and citizens' comments in the private press relating to these issues. It concludes that such perceptions about taxation illustrate the challenges confronting African states if they seek to expand their capacity for domestic resource mobilisation through taxation.
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Books

Advances in Taxation Some full text available
Internal Revenue Code section 162(m) limits tax deductibility of executive compensation to $1 million per covered executive, with an exception for performance-based compensation. Both stock options and annual bonuses can qualify as performance-based, but they vary in the difficulty of qualification and the degree of additional compensation risk that qualification imposes on the executive. Most stock-option grants easily qualify with little change in risk, but qualification increases the risk associated with annual bonus compensation relative to what it was prior. The results of this study show that the propensity to issue stock options has increased for affected executives as a percentage of total compensation. Additional analysis suggests that this increase in stock-option compensation is substituting for lower increases in salary for affected executives, but not for annual cash bonuses. In fact, the results suggest that bonus compensation is also increasing as a percentage of total compensation. In summary, the results indicate that firms and their executives are acting in a way consistent with the incentives provided by section 162(m).
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Empirical Foundations of Household Taxation Some full text available
The papers in this volume are the product of an ongoing NBER study of the effects of tax policies on household behavior. They present new statistical findings on how taxes affect household behavior or new analytical results on the effects of different types of tax policy. All of this research relies on household-level data, either drawn from publicuse tax return files provided by the U.S. Treasury or from large householdlevel surveys, to explore various aspects of the relationship between taxes and household behavior. Most of the studies employ the TAXSIM model, an NBER-supported computer program that facilitates study of how changing tax rates or tax rules would affect the tax liabilities of taxpayers in different circumstances.

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Germany's new rules on profit allocation to insurance PEs. Some full text available
The article explains how the profit allocation rules for insurance permanent establishments (PE) in Germany potentially discriminate against foreign insurance companies. The amendment of the Foreign Tax Act and the introduction of the authorised Organisation for Economic Cooperation and Development (OECD) approach (AOA) for attributing profits to PEs are discussed. Key aspects of the PE regulations include PE profit and loss calculation, asset allocation, and domestic insurance PEs.
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Global perspectives taxation e-commerce law Some full text available
Taxation of e-commerce is a major concern for international agencies and tax authorities worldwide. In its most advanced form, e-commerce allows unidentified purchasers to pay obscure vendors in ‘electronic cash’ for products that are often goods, services and licenses all rolled into one. A payee may be no more than a computer that can take up ‘residence’ anywhere; national boundaries are of no consequence whatsoever. The current debate over taxation of e-commerce has, to some extent, been little more than a rehash of a similarly inconclusive scholarly and legislative debate that raged over mail-order sales during the 1980s. However, in the case of e-commerce, the added question is how to reconcile national fiscal boundaries with the border less world of the internet.
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Global perspectives taxation on E-commerce law Some full text available
The relationships between taxation and technological developments have always been interactive, dynamic and complex. Law-making can be slow and tedious but technology often proceeds at breakneck speed. What are the implications of this apparent temporal gap between technological innovation and legal change? On the downside, the gap in time promotes legal uncertainty where affected parties cannot fully understand their legal rights and obligations.
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Globalization and Corporate Taxation Some full text available
This paper explores the conditions under which financial globalization (FG) in particular is likely to have a direct effect on corporate tax policy, and when and how that effect is expected to be negative or otherwise. The strategic framework facing governments in which a “Stackelberg” type of leadership by the United States or another major trading partner is also postulated to play a role. The basic notion is that side by side with FG, deviations from U.S. (or other major trading partner) corporate tax rates, up or down, are unlikely to be sustained over the longer term. In this, it provides extensive empirical evidence of the interaction between FG and strategic aspects, which is more general than the strategic behavior.
note: E-books
Globalization and Corporate Taxation Some full text available
This paper explores the conditions under which financial globalization (FG) in particular is likely to have a direct effect on corporate tax policy, and when and how that effect is expected to be negative or otherwise. The strategic framework facing governments in which a “Stackelberg” type of leadership by the United States or another major trading partner is also postulated to play a role. The basic notion is that side by side with FG, deviations from U.S. (or other major trading partner) corporate tax rates, up or down, are unlikely to be sustained over the longer term. In this, it provides extensive empirical evidence of the interaction between FG and strategic aspects.
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International Taxation and Multinational Activity Some full text available
The hypothesis that tax policies have negligible influence on the activities of multinational firms has been subjected to careful quantitative scrutiny over the last decade, with few (if any) of its implications emerging intact. Recent evidence indicates that taxation significantly influences the location of FDI, corporate borrowing, transfer pricing, dividend and royalty payments, and R&D performance.
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Land Value Taxation : Theory, Evidence, and Practice Dye, Richard F. England, Richard W. Some full text available
Among economists, a tax on land value is renowned for being an especially efficient tax because it produces few unintended costs while raising revenue. What does this mean? Taxes are normally levied on economic activity or assets to raise financial resources for the government. However, in addition to producing tax revenues, taxes typically raise the market price of the good that is taxed, which makes consumers buy less of it. The resulting reduction in production and consumption of the good is a distortion caused by the tax, and this reduction imposes an additional cost on the local economy. When a tax does not affect the amount of the commodity produced or consumed, there is no additional cost, and such a tax is more efficient (less costly to the local economy) than other taxes that reduce production. Land is one of the special commodities whose amount is fixed and unaffected by a tax on its value, so economists agree that a tax on land value is efficient.
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Principles of Political Economy and Taxation Some full text available
The value of a commodity, or the quantity of any other commodity for which it will exchange, depends on the relative quantity of labour which is necessary for its production, and not on the greater or less compensation which is paid for that labour.
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Studies in International Taxation Some full text available
This volume includes nine papers that were prepared as part of a research project on international aspects of taxation, undertaken by the National Bureau of Economic Research. The authors present new empirical studies of effects of tax policy on decisions of multinational corporations in three areas: international financial management, investment, and income shifting. This research was the focus of a conference attended by academics, policymakers, and representatives of international organizations. The conference was held in New York on September 26-28, 1991.
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Taxation : An Interdisciplinary Approach to Research Some full text available
This book introduces ‘an interdisciplinary research approach’ and comments upon how disciplinary-based approaches to tax research have developed in law, economics, accounting, political science, and social policy. Topical studies provide bibliographic surveys of specific areas of tax research. In this introductory chapter I explain the objectives of this book, the background in which it was developed, its approach, and its outline content.
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Taxation and Development— Again Some full text available
This welcome resurgence of interest makes it timely to take stock of experience and lessons in the area, and to assess newer challenges to resource mobilization in developing countries, such as those from globalization. But that is not the purpose here; this chapter does not aim to provide a sweeping review of technical issues, largely because there is no shortage of surveys and there are quite a few books on resource mobilization and development. 4 Nor is the aim to identify important areas for research or methodological improvement, though there will be some of that. (This volume itself is evidence of the importance and value of strengthening empirical work in the area). Instead the purpose of this essay is to reflect, no doubt idiosyncratically, on some wider issues in the practical advice that developing countries are commonly given on tax matters.
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Taxation and Leverage in International Banking Some full text available
This paper explores how corporate taxes affect the financial structure of multinational banks. Guided by a simple theory of optimal capital structure it tests (i) whether corporate taxes induce subsidiary banks to raise their debt-asset ratio in light of the traditional debt bias; and (ii) whether international corporate tax differentials vis-a-vis foreign subsidiary banks affect the intra-bank capital structure through international debt shifting. Using a novel subsidiary-level dataset for 558 commercial bank subsidiaries of the 86 largest multinational banks in the world, we find that taxes matter significantly, through both the traditional debt bias channel and the international debt shifting that is due to the international tax differentials. The latter channel is more robust and tends to be quantitatively more important. Our results imply that taxation causes significant international debt spillovers through multinational banks, which has potentially important implications for tax policy.
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Taxation in the Global Economy Some full text available
The globalization of economic activity over the past three decades is widely recognized. Despite recent indications of renewed protectionism, this trend is likely to continue. With the integration of international activity has come the awareness that countries are linked not only by the cross-border transactions of private firms and citizens but also by the cross-border ramifications of their governments’ fiscal policies. The tax policy of one country can affect economic activity in other countries, and in the choice of tax policy instruments a policymaker must consider its international consequences.
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The Theory of Taxation and Public Economics Some full text available
This book develops and applies a unifying framework for the analysis of taxation and related subjects in public economics. Its two central features are explicit attention to the social objective of welfare maximization and direct examination of how various government instruments should be orchestrated to achieve that objective. Consistent application of this approach solidifies and extends some familiar results and intuitions, overcomes seemingly intractable obstacles regarding other issues, and overturns several important settled understandings.
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US Taxation of Foreign Income Some full text available
The case for reforming US taxation of international business income is particularly acute in high-technology activities and industries. Those who are content with the US position in the world economy, those who believe that the dominant purpose of tax policy is to raise revenue in a manner that creates the least political stir— or in a manner that is neutral across all forms of economic activity— and those who see only a weak link between tax policy and corporate performance will find little reason to commend this book. Our recommendations are based on the central proposition that the US position in the world economy should be stronger and that, at the margin, tax policy can make a difference. We readily acknowledge that other forces also matter, such as education, workforce skills, innovation, and cultural attitudes.
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Open Access Resources

Ask Now of the Days that are Past openURL
Written for a general audience, the essays collected here present refreshing and often humorous glimpses of various topics in Jewish history and traditional religious literature. Inspired by the diversity of Jewish thought, author and scholar Eliezer Segal sheds light on the social and political forces that have brought the Jewish community together in the past and still speak with familiarity to a modern western culture. Enlightening and entertaining, Professor Segal's writing is a rare blend of scholarship and wit, highlighting contemporary experiences that bring the rich heritage of Jewish civilization to life for the everyday reader. With an extensive and broad knowledge of ancient and medieval Jewish social and religious traditions, Segal deftly crafts anecdotes and explanations that address the tribulations of contemporary life. From topics as diverse as panhandling, tennis, vampires, and the history of the tomato to themes as universal as weddings, charity, and taxation, the essays presented here, some for the first time in English, all include detailed notes on sources for further reading. Equally suited to those after a light-hearted romp or those on a serious quest for knowledge, Ask Now of the Days that Are Past is sure to satisfy anyone who has ever wondered how the past still influences us today.
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Political concepts openURL
Written by a powerful international team of theorists, this book offers a sophisticated analysis of the central political concepts in the light of recent debates in political theory. All political argument employs political concepts. They provide the building blocks needed to construct a case for or against a given political position. To address such issues as whether or not development aid is too low, income tax too high, or how to cope with poverty and the distribution of wealth, citizens must develop views on what individuals are entitled to, what they owe to others, and the role of individual choice and responsibility in these areas. These matters turn on an understanding of concepts such as rights, equality and liberty and the ways they relate to each other. People of different political persuasions interpret such key political concepts in different ways. This book introduces students to some of the main interpretations, pointing out their strengths and weaknesses. It covers a broad range of the main concepts employed in contemporary political and theoretical debates. Separate chapters look at liberty, rights, social justice, political obligation, nationalism, punishment, social exclusion, legitimacy, the rule of law, multiculturalism, gender, public and private, democracy, environmentalism, international justice and just war. This book is perfect for students of political theory and political ideology, and indeed anyone approaching political theory for the first time.
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Considerations on the phenomenon of double taxation in the European union openURL
In the general context of economic globalization, international economic cooperation, the liberalization
movement of goods, services, capital and persons, and the effect of the exercise of fiscal sovereignty, appears the
phenomenon of double or multiple international taxation of income and assets, following the vocation of several
legal systems, which contain legislative differences and can generate tax obstacles, such as, the laws of the
country of origin of the revenue and the legislation of the country of destination of income.
Thus, more interesting becomes the study of the phenomenon of double taxation at EU level given the distinct
presence of 27 sovereignties in full process of European integration
So, this paper aims to identify how the European Union handles the phenomenon of double taxation, making a
shift from defining this phenomenon to identifying the legislation designed to avoid or eliminate the phenomenon
of double taxation in the field of EU direct taxation.
Also, this paper deems necessary to stop a moment upon the fiscal harmonization and integration in the indirect
taxation field of the European Union.
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Double divided and taxation relief: a new view from thecorporate income tax pespective openURL

Double taxation of dividends is a matter of great i
interest in the actual context of globalization
and free movement of capital and persons. As the
classical system is more and more abandoned, new
solutions for the relief of double taxation are put
into practice as a mean to reduce the fiscal burden
on shareholders. With few exceptions, all these solutions are based on dividend tax relief. The paper
aims at providing alternative solutions for double
dividend taxation relief by taking some actions on
corporate taxation and leaving aside personal incom
e taxation. The goal of the research is to provide
a new methodological approach of dividend taxation
in various systems of taxation, the results show-
ing which system is more suitable and easy to be pu
t into practice. The results showed that the
deduction system of dividends when computing taxable
e profits is the most appropriate for the Roma-
nia’s flat tax fiscal framework.
note: Journal for Open Access
Taxation affecting the attractiveness of central and eastern European countries for fid? openURL

The target of this paper is to determine whether taxation affects the attractiveness of Central and Eastern
Europe (CEE) countries for foreign investors. In this scope, the paper analyzes the impact of taxation for the
location decision of foreign direct investment (FDI) in CEE countries both in 2007 and 2010. A taxation index
investing the effect of multiple host coun
try taxes is developed in order to dr
aw the attractiveness matrix for the
countries taken into account. The ta
xation level comprises the corporate in
come tax rate, representing direct
taxation, the value-added tax (VAT) and the social security contributions expressing indirect taxation and finally the
ease of paying taxes, as provided in Doing Business report. The results indicate that relieving the burden of paying
taxes by tackling the taxation issue is a mean for improving the FDI attractiveness of a country. Still, there are other
factors that have higher influence on FDI inflows. The main finding is that there is no perfect correspondence
between the shifts in taxation rankings and the FDI inflows performance
note: Open Acces Resources Journal
Taxation and the Financial Crisis openURL
The financial crisis has opened up a global debate on the taxation of the financial sector. A number of international policy initiatives, most notably by the G20, have called for major changes in the tax treatment of financial institutions and transactions as well as individuals working in the financial sector. This book examines how tax policies contributed to the financial crisis and whether taxation can play a role in the reform efforts under way to establish a sounder and safer financial system. The book looks at the pros and cons of various tax initiatives, including limiting the tax advantages to debt financing, special taxes on the financial sector and financial transactions taxes.
note: Books:open access resources
The Ayes Have It: The History of the Queensland Parliament 1957-89 openURL
The Ayes Have It’ is a fascinating account of the Queensland Parliament during three decades of high-drama politics. It examines in detail the Queensland Parliament from the days of the ‘Labor split’ in the 1950s, through the conservative governments of Frank Nicklin, John Bjelke- Petersen and Mike Ahern, to the fall of the Nationals government led briefly by Russell Cooper in December 1989. The volume traces the rough and tumble of parliamentary politics in the frontier state. The authors focus on parliament as a political forum, on the representatives and personalities that made up the institution over this period, on the priorities and political agendas that were pursued, and the increasingly contentious practices used to control parliamentary proceedings. Throughout the entire history are woven other controversies that repeatedly recur – controversies over state economic development, the provision of government services, industrial disputation and government reactions, electoral zoning and disputes over malapportionment, the impost of taxation in the ‘low tax state’, encroachments on civil liberties and political protests, the perennial topic of censorship, as well as the emerging issues of integrity, concerns about conflicts of interest and the slide towards corruption. There are fights with the federal government – especially with the Whitlam government – and internal fights within the governing coalition which eventually leads to its collapse in 1983, after which the Nationals manage to govern alone for two very tumultuous terms. On the non-government side, the bitterness of the 1950s split was reflected in the early parliaments of this period, and while the Australian Labor Party eventually saw off its rivalrous off-shoot (the QLP-DLP) it then began to implode through waves of internal factional discord.
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The International Double Taxation – causes and avoidance openURL
The politics and tax legislation being a manifest
ation of strict sovereignty of the State, the
phenomenon of double taxation occurs frequently rep
resenting a difficult poison for the foreign trade
activity, especially hindering investments abroad,
technology transfer or proliferation outside of the
state of the companies’ branches. Therefore, intern
ational legal double taxation, by the repeated
taxation of the income, it is an obstacle to the de
velopment of economic relations between states,
reducing the revenue of the international operators
and their interests in making investment abroad.
This
paper presents the main causes that determine doubl
e taxation, its forms, i.e. the economic double
taxation and the international legal double taxatio
n, the need for eliminating the double taxation and
avoidance methods.
note: A journal from Open Access
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